GTxcel, Inc. and its subsidiaries (“GTxcel” also referred to as “we” or “us”) provide this Privacy Policy to help you understand how we collect, use, and disclose information, including personal information that you may provide to us, information that may be obtained through your use of this website.. This Privacy Policy applies only to this website, at www.gtxcel.com (“Website”), and GTxcel email, and does not apply to any other GTxcel websites, any website or digital edition we may create for a customer, or to any third-party websites. BY VISITING OUR WEBSITE, YOU SIGNIFY YOUR AGREEMENT TO THIS PRIVACY POLICY AND CONSENT TO THE COLLECTION AND USE OF YOUR PERSONAL INFORMATION BY GTXCEL CONSISTENT WITH THIS PRIVACY POLICY. PLEASE READ THIS PRIVACY POLICY TO UNDERSTAND OUR PRACTICES. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, DISCONTINUE ALL USE OF OUR WEBSITE.

Our Website is not directed toward children (minors under 13 years of age). We do not knowingly collect Personal Information from children.

Please note that this Privacy Policy applies only to our website and email, and the online collection and use of information and does not apply to any information that you may provide to us by other means, such as via regular mail or telephone.

If you receive mailings from us and prefer not to receive these mailings, or if you have questions or wish to send us comments about this Privacy Policy, please mail your questions or comments to:

“Personal Information” means information that alone or when in combination with other information may be used to readily identify, contact, or locate you or a specific individual.

2. INFORMATION YOU PROVIDE TO US

User Registration. You may be asked to share Personal Information such as your name, company name, title, address, telephone number, email address, and other information, when you seek information, make purchases, or otherwise interact with GTxcel.

We may also use the information you provide in online registration forms to notify you periodically about important changes to the Website (such as a change to this Privacy Policy or notice of a security breach). We may also notify you, the publisher, about new GTxcel services, and special offers and promotions that may be of interest to you; we will in no event contact your customers or subscribers.

We may collect Personal Information when you participate in activities on our Website, such as informational and promotional offers, when you request a newsletter, and when you provide information to our customer service representatives.

Social Media. We do not control or have responsibility for the acts of Users of the Website. Please be aware that if you disclose personal information through social media, in a bulletin board, chat room or other public forum, that information may be used by others. Our Website may offer public forums such as message boards, conversation pages, chat rooms, profile pages (“Public Forums”). If you provide Personal Information through the Public Forums, that Personal Information may be publicly posted through the Public Forum and otherwise disclosed without limitation as to its use by a third party.

Online Promotions, Contests and Sweepstakes. You may be asked to provide an email address or screen name, or other Personal Information, for entry into a particular promotion, including sweepstakes and contests, so that we can let you know if you won a prize. The specific rules and regulations governing the particular promotion, contest or sweepstakes will vary and your participation constitutes your agreement to abide by those rules and regulations. Certain promotions, contests or sweepstakes may be run by a GTxcel service provider or vendor or co-branded with one of our partners. In these instances the collection of your Personal Information may occur directly by the service provider or vendor or a third-party partner on their website. The promotion will state the privacy policy or policies governing the collection of such information if they should differ from this Privacy Policy.

Children. The GTxcel Website is not directed at children. If you are under 18 or otherwise would be required to have a parent or guardian consent to share information with GTxcel, you should not send any information about yourself to us. As required by law, if a person under 13 submits information through any part of a GTxcel Website, and we learn the person submitting the information is such a child, we will attempt to delete this information as soon as possible.

3. INFORMATION COLLECTED THROUGH TECHNOLOGY

Data. We collect information through technology to make our Website more interesting and useful to you and for various purposes related to our business. For example, we may collect information about your access time, computer configuration, type of browser software, operating system, resolution of your computer monitor, and your Internet Protocol (“IP”) address. Standing alone, your IP address is not Personal Information. We may also collect your installation ID if you are using a mobile device such as a phone or tablet. The installation ID, standing alone, is not Personal Information. GTxcel (or GTxcel vendors) may observe your activities, preferences, and transactional data (such as your IP address and browser type) as well as related usage behavior depending on whether you are using our Website or a particular GTxcel Service. We may use this data for any purpose in connection with a particular Website or our business. While we may collect or log this information, we do not identify you or match this non-Personal Information with your Personal Information unless we believe doing so will help us better respond to a request you have made. Where such non-Personal Information is linked to your Personal Information we will treat such combined information as Personal Information. For information about specific GTxcel services, please see specific privacy notices directed to such services.

Cookies. Our Website collects information through a variety of technical methods, including cookies and Web beacons. A cookie is a text file stored on a user’s hard drive that a Web site sends to your computer while you are viewing the Web site. It contains no Personal Information. Web beacons are small pieces of data that are embedded in images on the pages of Website. Cookies, Web beacons and other technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. Cookies are not used to retrieve any Personal Information from the user’s computer.

We may use the information collected through these technical methods for many purposes, including delivering content, tracking and enhancing individuals’ experiences on our Website. We also may use technical methods to analyze the traffic patterns on our Website, such as the frequency with which our users visit various parts of our Website, and third party Website, such as the frequency with which our users visit other Website. In HTML e-mails that we send our guests, we may use technical methods for a number of purposes, including: to determine whether our guests have opened or forwarded those e-mails and/or clicked on links in those e-mails, and to determine whether a person has made an inquiry or purchase in response to a particular e-mail. These technical methods may enable us to collect and use information in a form that may amount to Personal Information.

4. INFORMATION THAT WE COLLECT FROM OTHERS

If we obtain Personal Information about you from third parties, we will treat all your Personal Information that we obtain from others with the same care as that for other Personal Information as described in this Privacy Policy.

5. DISCLAIMER ABOUT LINKS TO THIRD-PARTY WEBSITES

This Website or may contain links to third-party websites and social networking services, however, please be aware that GTxcel is not responsible for and cannot control the privacy practices of any other websites or social networking services. We encourage you to read the privacy policies for these other websites. This Website also contains links to co-branded websites that may display GTxcel’s logo and trademarks but which are maintained by third parties. Such websites may be identified by the fact that they do not display a “GTxcel.com” URL. If you click on a third-party link or an advertisement on one of our Website or apps and link to a third party’s Web site, then our Privacy Policy will not apply to your Personal Information collected on that third party’s website and you must read the privacy policy posted on that site to see how your Personal Information will be handled. We do not monitor or control the information collection or privacy practices of third parties, and are not responsible for their practices or the content of their website, including, without limitation, their use of any information.

This Privacy Policy applies solely to information collected by GTxcel on its Website or online.

6. WHEN GTXCEL MAY SHARE COLLECTED INFORMATION

As mentioned in the beginning of this Privacy Policy, GTxcel may share Personal Information within GTxcel and with its affiliates and vendors to fulfill its obligations to you and operate its business, consistent with this Privacy Policy. In addition, we may share your Personal Information with third parties in the following situations:

GTxcel Affiliates and Vendors. GTxcel works with many affiliated third parties and vendors. So that these groups may provide their products and services to us and provide any information you have requested, these third parties may have access to or process your Personal Information. GTxcel may also sometimes permit our authorized service providers to have access to aggregate statistics about our customers, sales, traffic patterns, and related Website information. These transfers of aggregate statistics do not involve Personal Information.

Recruitment and Job Applications. Residents of the United States may provide us with Personal Information through our Website or through email. Personal information such as that contained on a resume or curriculum vitae may be submitted in connection with a job application or inquiry. We may use this information throughout GTxcel for the purpose of employment consideration or your inquiry. We may keep your information on file for future consideration. For clarification, the above paragraph and this entire Privacy Policy applies only to this Website and not to any website created for customers or digital editions.

Enabling Services. Personal Information that is collected through the Website may be used and/or disclosed to third parties in order to enable us to provide GTxcel services. For example, the Website may allow you to interface with a third party website, social media, or application. To facilitate that connection, we may use your Personal Information and/or disclose your Personal Information to third parties.

Public Areas/Social Media. Any information disclosed in public areas of a GTxcel Website (e.g., Facebook, YouTube, Twitter, etc.) will become public information. We cannot control the use of information disclosed in public forums, such as social media, bulletin boards, blogs, chat rooms, and tweets. You should exercise caution when disclosing information in these public areas, and be careful how you disclose your Personal Information. Content posted in public areas of the GTxcel Website, including advice and opinions, represent the views and is the responsibility of those who post the content. GTxcel does not necessarily endorse, support, verify, or agree with the content posted.

Mergers, Acquisitions, and Insolvency. If GTxcel should ever file for bankruptcy or merge with another company, or if GTxcel should decide to buy, sell, or reorganize some part or all of its business, GTxcel may be required to disclose your Personal Information to prospective or actual purchasers in connection with one of these transactions

As Required by Law and Other Extraordinary Disclosures. GTxcel may be required to disclose your Personal Information if it: (i) believes it is reasonably necessary to comply with legal process (such as a court order, subpoena, search warrant, etc.) or other legal requirements of any governmental authority; (ii) would potentially mitigate our liability in an actual or potential lawsuit; (iii) is otherwise necessary to protect our rights or property; or (iv) is necessary to protect the legal rights or property of others.

GTxcel Promotional Uses. We may also notify you, the publisher, about new GTxcel services, and special offers and promotions that may be of interest to you; we will in no event contact your customers or subscribers. These promotional materials may be sent to you by postal mail, email or other means. You may opt out of receiving these communications as provided in below.

When you purchase or request services (or information about services) from the Website, promotional materials about goods and services offered by another GTxcel website and/or by a third party may accompany delivery of the service or information that you have requested. Because these promotional materials accompany services or information that you have requested, your opt-outs for GTxcel mail or email will not apply to any third-party promotions.

Operational Uses. GTxcel may also use your Personal Information for many purposes other than sending you promotional materials. (We refer to all of these types of uses of your personal information that do not involve the sending of promotional materials as “Operational Uses.”) For example, we may use your information to complete transactions requested by you (such as your purchase of a service offered by us), or to send you administrative communications either about your account with us or about features of our Website or services ordered by you.

Sometimes GTxcel also works with other companies who facilitate transactions with you and help either gather your information or communicate with you, such as a company that helps to provide customer service. Your opt-out choices will not apply to sharing by GTxcel of your personal information with any of these companies. These companies are allowed to gather, receive, and use your information only for the purposes described in this paragraph or to facilitate compliance with laws.

As another example of Operational Uses, we may share your Personal Information with the GTxcel telephone service center or third party telephone service centers contracted by GTxcel, so that the service center operators are able to respond immediately to your questions or requests when you call, rather than asking you to provide your information a second time. Because these uses of your Personal Information do not involve sending you promotional materials and may be necessary to fulfill your account with us, your opt-outs will not apply to any of these Operational Uses.

Non-Personal Information. GTxcel may take your Personal Information and make it non-Personal, either by combining it with information about other individuals (aggregating your information with information about other individuals), or by removing characteristics that make the information personal to you (de-personalizing your information). We may use such non-Personal information in aggregate form in our business and to provide statistical information based on this data to advertisers, affiliates, clients, and other current and potential business partners.

8. CHOICES YOU HAVE ABOUT THE COLLECTION AND USE OF YOUR PERSONAL INFORMATION

Your opt-out choices are as follows:

Third Parties. When you order products from third parties through GTxcel, you may receive third party promotional materials over which GTxcel has no control. Your opt-out choices for third parties generally are specific to the parties from which you purchase products.

GTxcel. You may correct, change, or delete your Personal Information by contacting GTxcel at the address above. You may also opt-out of promotional materials within emails by following a link in the email to opt-out. Any opt-out choices you make will not apply in situations where (a) you either have made, simultaneously make, or later make a specific request for information from GTxcel, (b) GTxcel shares your Personal Information as described herein. Also, any opt-out choices you make will not apply to Personal Information that you provide about other persons, but these other persons will have the opportunity to opt out of receiving promotional materials.

In addition, any time that we send you promotional materials that you have consented to receive under one of the previously described opt-out choices, we may accompany those materials with other promotional materials, which will be covered by the other opt-out choices.

9. SUPPLEMENTAL PRIVACY NOTICE TO CALIFORNIA RESIDENTS

If you are a resident of California, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information, if any, by us to a third party for the third party’s direct marketing purposes. This right granted to California residents applies only to their activities within the State of California. To make such a request, please send an email to Privacy@GTxcel.com or write us at: Customer Service, 144 Turnpike Road, Southborough, MA 01772.

10. SECURITY

If GTxcel learns of a security system’s breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using this Website or a GTxcel Service or providing Personal Information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of this Website or GTxcel Service. GTxcel may post a notice on this Website if a security breach occurs. If this happens, you will need a web browser or mobile device enabling you to view the GTxcel Website or application. GTxcel may also send an email to you at the email address you have provided to us in these circumstances or communicate with you by other means if we can. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

11. SPECIAL NOTICE TO INTERNATIONAL VISITORS AND CUSTOMERS

Because GTxcel operates globally, we may transfer your Personal Information within our global operations to fulfill our obligations to you, but always subject to the limitations of applicable data protection law and this Privacy Policy. Privacy laws differ across the globe. If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, including those whose privacy laws may be more strict than U.S. law, please note that you are transferring your personal data to the United States to GTxcel. By providing your personal data you consent to that transfer and processing.

12. CHANGES TO THIS PRIVACY POLICY BY GTXCEL

We reserve the right to change this Privacy Policy in the future. If in the future we change our Privacy Policy, we will post the new Privacy Policy on this Website or Application. Your continued use of this Website or GTxcel Product following a change in the Privacy Policy represents consent to the new Privacy Policy to the fullest extent permitted by law. We encourage you to periodically review this Privacy Policy.

Please note that, at all times, you are responsible for updating your Personal Information to provide us your current email address. In the event that the last email address that you have provided us is not valid, or for any other reason is not capable of delivering to you any notices described herein, our dispatch of the email containing such notice will nonetheless constitute effective notice of the amendment described in the notice.